or cease and desist by D6K9rJ4B

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									  Operation Rescue, or any organizational name under
  which you currently operate

  P.O. Box 782888
  Wichita, KS 67278-2888
  Fax: 916-244-2636




Cheryl Sullenger, Troy Newman, and Operation Rescue:

This CEASE AND DESIST LETTER is to inform you that the articles written and posted on
www.operationrescue.org regarding me, A. Kristin Neuhaus, MD, are untrue and defamatory. You
maliciously made these defamatory statements to the press and public in an attempt to damage my trade,
reputation and profession. As such, they are defamatory per se K.S.A 21-4005, this letter constitutes a
demand for immediate retraction, in writing, of these false and libelous statements. In accordance with
K.S.A 21-4005(a)(b), I demand that your retraction and correction be accompanied by an editorial in
which you specifically repudiate your libelous statements.

This letter is to demand that your continuing involvement in, planning, and encouragement of damaging
and untruthful comments toward me must CEASE AND DESIST immediately. Should you or any other
member of your organization continue to pursue these activities in violation of this CEASE AND DESIST
LETTER, I will not hesitate to pursue legal action against Cheryl Sullenger, Troy Newman and Operation
Rescue, including, but not limited to, civil action and/or criminal complaints. As such, they are actionable
and expose you to the imposition of compensatory as well as punitive damages.

I am aware of numerous incidences of libel with actual malice towards me, perpetrated by you/your
organization over the past year, in an apparent effort to influence the outcome of the complaint that you
filed with the Kansas Board of Healing Arts. These incidents include, but are not limited to: 1) your claim
that I sedated and forcefully performed an abortion on a patient, in spite of her later testimony under oath
that she had not withdrawn consent, and had in fact, filed the complaint in hope of financial gain; 2) gross
misrepresentations of fact and intentionally malicious statements meant to influence members of the
public to view me in an unfavorable light, such as, that I am “unfit to practice medicine” and “a danger to
the public.” You have made these statements repeatedly, to members of the press, and on your website
www.operationrescue.org. All of these incidences constitute libel. This shameful campaign tactic must stop
immediately before any further libelous damage to my reputation occurs.

Relevant Kansas Statutes:

Chapter 21 http://kansasstatutes.lesterama.org/Chapter_21: Crimes And Punishments PART II.--
PROHIBITED CONDUCT Article 40 <http://kansasstatutes.lesterama.org/Chapter_21/Article_40/>:
Crimes Involving Violations Of Personal Rights Statute 21-4004: Criminal defamation. (a) Criminal
defamation is communicating to a person orally, in writing, or by any other means, information, knowing
the information to be false and with actual malice, tending to expose another living person to public
hatred, contempt or ridicule; tending to deprive such person of the benefits of public confidence and social
acceptance; or tending to degrade and vilify the memory of one who is dead and to scandalize or provoke
surviving relatives and friends. (b) In all prosecutions under this section the truth of the information
communicated shall be admitted as evidence. It shall be a defense to a charge of criminal defamation if it is
found that such matter was true. (c) Criminal defamation is a class A nonperson misdemeanor. History: L.
1969, ch. 180, § 21-4004; L. 1992, ch. 239, § 187; L. 1993, ch. 291, § 135; L. 1995, ch. 251, § 14; July 1.

Kansas additionally recognizes that certain cases of statements qualify as "defamatory per se." This means
that the parties seeking justice do not have to prove that the statement was "defamatory." This follows the
common law tradition that the damages for these "per se" statements are presumed. The following
examples usually qualify under this "per se" distinction: allegations or imputations that are injurious to
a party in his trade, profession or business, allegations that an individual has a "loathsome" disease (such
as a STD), allegations that an individual is lacking in chastity, and allegations of criminal activity or
conviction.

Kansas is one of only a few states that have criminal defamation laws. These require a higher standard of
proof for conviction. The higher threshold of proof is "actual malice" for a party to be convicted of
defamation in Kansas. This level of malice requires that the party must actually know that the statements
or printed statements are false. One exception to this threshold of "knowing" occurs in instances where
the party should have known the statements were false.

I have a right to remain free from libelous, manipulative and high-pressure tactics directed toward the
Kansas Board of Healing Arts, and via the media, at the citizens of Kansas. Note that a copy of this letter
and a record of its delivery will be stored. Note too that it is admissible as evidence in a court of law and
will be used as such if need be in the future. This CEASE AND DESIST LETTER demands that you
immediately discontinue and do not at any point in the future under any circumstances do the following:
misrepresent my character, fabricate lies about any events related to me, put yourself forward to the
public as having any competence to evaluate my professional judgment or behavior, or make any other
slanderous or libelous comments about me. Should you willfully choose to continue your current course
of action, I will not hesitate to file a complaint for your ongoing violations of the civil and criminal laws
noted previously. This letter does not constitute exhaustive statement of my position nor is it a waiver of
any of my rights and/or remedies in this and/or any other related matter. I demand your immediate
compliance, and furthermore that you confirm in writing that all violative activity will cease immediately.

Regards,




Kristin Neuhaus, MD

cc:
Robyn Shepherd, ACLU National
Holly Weatherford, ACLU of Kansas and Western Missouri
and approximately 200 national and state news organizations




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